CCTV Policy

Closed circuit television (CCTV) is installed at the Practice premises for the purposes of patient, staff and premises security. Cameras are located in the reception, lobby and

external area of the premises.

The use of CCTV falls within the scope of the Data Protection Act 1998 (“the 1998 Act”). This

code of practice follows the recommendations issued by the Data Protection Commissioner

in accordance with powers under Section 51 (3)(b) of the 1998 Act.

In order to comply with the requirements of the 1998 Act, data must be:

Fairly and lawfully processed

Processed for limited purposes and not in any manner incompatible with those purposes

Adequate, relevant and not excessive

Accurate

Not kept for longer than is necessary

Processed in accordance with individuals' rights

Secure

In Summary

1) CCTV is in place in the reception of the premises.

2) CCTV has been installed solely for the safety and security of our patients, staff and premises.

3) Images are captured 24 hours a day, seven days a week and are processed via our CCTV capturing devices. These devices are securely protected and only the owner of the practice and the data protection officer have access to the equipment. The owner regularly checks that the CCTV devices are working as intended.

4) The CCTV only captures images and does not record audio.

5) Signs informing visitors that CCTV is in place can be found at reception area of the premises.

6) We inform visitors to our website that CCTV will be in operation.

7) The recording devices have the capability of transferring data to an external cloud based storage for cooperation with the relevant authorities. We only ever do this where there is

cause to believe the safety and security of patients/staff has been compromised. We do not ever share images with other third parties.

8) Visitors to the practice have the right to request to see images of themselves on CCTV as part of a Data Protection request. Like all Data Protection requests, this request must be made in writing and the same exceptions apply. There is no charge for this (unless there is an exceptional level of work collating the data). We will also require information that will allow us to identify the visitor and the date/time of the visit.

9) We have followed the CCTV guidelines produced by the Information Commissioners’

Ms. Carole Marina Hewison is the Data Controller under Section 4(4) of the Act.

CCTV is installed for the purpose of staff, patient and premises security.

Use of images, including the provision of images to a third party, will be in accordance with the Practice’s Data Protection registration.

Signage is displayed at the premises and on the Practice website stating of the presence of CCTV.

Retention of images

Images from cameras are recorded on disc/computer system (“the recordings”).

The recordings are made and retained for the purposes of security of staff, patient and

premises, these will be held in secure storage, and access controlled. Recordings will not be

retained for longer than thirty days.

Access to images

It is important that access to, and disclosure of, images recorded by CCTV and similar

surveillance equipment is restricted and carefully controlled, not only to ensure that the

rights of individuals are preserved, but also to ensure that the chain of evidence remains

intact should the images be required for evidential purposes.

Access to images by practice staff

Access to recorded images is restricted to the owner of Elite Dental Practice and the data protection officer who will decide whether to allow requests for access by Data Subjects and/or third parties

Viewing of images must be documented as follows:

The name of the person removing from secure storage, or otherwise accessing, the recordings

The date and time of removal of the recordings

The name(s) of the person(s) viewing the images (including the names and organisations of any third parties)

The reason for the viewing

The outcome, if any, of the viewing

The date and time of replacement of the recordings

Removal of images for use in legal proceedings

In cases where recordings are removed from secure storage for use in legal proceedings, the

following must be documented:

The name of the person removing from secure storage, or otherwise accessing, the recordings

The date and time of removal of the recordings

The reason for removal

Any crime incident number to which the images may be relevant

The place to which the recordings will be taken

The signature of the collecting police officer, where appropriate

The date and time of replacement into secure storage of the recordings

Access to images by third parties

Requests for access to images will be made in writing. There is no charge for this (unless there is an exceptional level of work involved in collating the data)

The Data Controllers of Elite Dental Practice will assess applications and decide whether the requested access will be permitted. Disclosure of recorded images to third parties will only be

made in limited and prescribed circumstances. For example, in cases of the prevention and detection of crime, disclosure to third parties will be limited to the following:

Law enforcement agencies where the images recorded would assist in a specific criminal enquiry

Prosecution agencies

Relevant legal representatives

The Press/Media, where it is decided that the public's assistance is needed in order to assist in the identification of victim, witness or perpetrator in relation to a criminal incident. As part of that decision, the wishes of the victim of an incident should be taken into account

People whose images have been recorded and retained (unless disclosure to the individual would prejudice criminal enquiries or criminal proceedings)

All requests for access or for disclosure should be recorded. If access or disclosure is denied,

the reason should be documented as above.

Access by data subjects

This is a right of access, which is provided by section 7 of the 1998 Act. Requests for access

to images will be made in writing. There is no charge for this (unless there is an exceptional level of work involved in collating the data)

Individuals should also be provided with the CCTV Policy and Code of Practice which

describes the type of images which are recorded and retained, the purposes for which those

images are recorded and retained, and information about the disclosure policy in relation to

those images.

Procedures for dealing with an access request

All requests for access by Data Subjects will be dealt with by Ms. Carole Marina Hewison.

The Data Controller will locate the images requested. The Data Controller will determine whether disclosure to the Data Subject would entail disclosing images of third parties.

The Data Controller will need to determine whether the images of third parties are held under a duty of confidence. In all circumstances the Practice’s indemnity insurers will be asked to advise on the desirability of releasing any information.

If third party images are not to be disclosed, the Data Controllers will arrange for the

Third – party images to be disguised or blurred. If the CCTV system does not have the facilities to carry out that type of editing, an editing company may need to be used to carry it out. If an editing company is used, then the Data Controllers must ensure that there is a contractual relationship between them and the editing company, and;

That the editing company has given appropriate guarantees regarding the security measures they take in relation to the images

The written contract makes it explicit that the editing company can only use the images in accordance with the instructions of the Data Controllers

The written contract makes the security guarantees provided by the editing company explicit

Ms. Carole Marina Hewison will provide a written response to the Data Subject within one month of receiving the request setting out the Data Controller’s decision on the request.

Complaints

Complaints must be in writing, and addressed to the practice owner. Where the

complainant is a third party, and the complaint or enquiry relates to someone else, the

written consent of the patient or Data Subject is required. All complaints will be

acknowledged within 7 days, and a written response issued within one month.